Compliance Officer & MLRO

PhotonPay; Dubai; On-site; AED 550,000 - 950,000; Full time

Job summary

PhotonPay seeks an experienced Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO) under the DFSA DIFC regime in Dubai. You will act as the main interface with DFSA, FIU, Central Bank where applicable, and external auditors, driving governance and regulatory reporting.

You will design and oversee AML/CFT programs, KYB/KYC onboarding, UTR investigations, and annual MLRO/Compliance reporting to the SEO and Board, while coordinating with Group Legal & Compliance to align DIFC

Qualifications

• Regulatory approvals and governance knowledge.
• Experience leading AML/CFT programs in DIFC/DFSA environments.
• Familiarity with cross-border fintech operations and regulatory requirements.

Responsibilities

• Design, implement, and maintain AML/CFT and Sanctions programs per DFSA modules.
• Oversee KYB/KYC onboarding, EDD for high-risk clients, and transaction monitoring.
• File SARs/STRs via FIU goAML and maintain statutory records.
• Prepare and present MLRO and Compliance reports to the Board/SEO.
• Harmonize local regulatory requirements with global policies across units.

Skills

Regulatory compliance

AML/CFT expertise

Cross-border payments

Global collaboration

Education

Bachelor's degree in Law/Finance/Business

CAMS

ICA qualification

CISI qualification

Tools

goAML

DFSA EPRS

Job description

• Serve as the DFSA-approved Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO) under the DIFC regulatory regime.
• Act as the primary interface with the DFSA, the United Arab Emirates Financial Intelligence Unit (FIU), United Arab Emirates Central Bank (where applicable), DIFC Data Protection Commissioner, and external auditors
• Manage regulatory communications, examinations, inquiries, statutory notifications, breach reportings and thematic reviews.
• Prepare and ensure the timely submission of all periodic and ad-hoc regulatory returns, notifications, and annual AML/Compliance reports to the DFSA.

2. Category 3D Specific Compliance & Governance

• Maintain, localize, and enhance the Compliance Manual, Risk Management Framework, and Compliance Monitoring Programme (CMP) tailored to Category 3D Money Services (including payment accounts, B2B cross-border remittances, card issuance, and merchant acquiring).
• Oversee strict adherence to DFSA Client Money Rules (COB Module), working closely with Finance and Operations to ensure proper safeguarding, segregation, and daily reconciliation of client funds.
• Ensure ongoing compliance with DFSA Category 3D operational thresholds, monitoring Expenditure-Based Capital Requirements and operational risk frameworks under the PIB Module.
• Provide compliance sign-off on new payment products, corridor expansions, banking/liquidity partnerships, and cross-border intercompany outsourcing arrangements.

3. AML/CFT & Financial Crime Compliance (MLRO Duties)

• Design, implement, and oversee the local AML/CFT and Sanctions compliance program in accordance with the DFSA AML Module and United Arab Emirates Federal AML legislation.
• Formulate, implement, and maintain the firm’s Business AML Risk Assessment (BARA) and Financial Crime Compliance Framework in accordance with the DFSA AML Module.
• Oversee complex KYB/KYC onboarding, Enhanced Due Diligence (EDD) for high-risk corporate clients/merchants, ongoing transaction monitoring, and sanctions screening.
• Investigate internal Unusual Transaction Reports (UTRs), file Suspicious Activity Reports (SARs/STRs) via the United Arab Emirates FIU goAML portal, and maintain statutory records.
• Produce and present the annual statutory MLRO Report and annual Compliance Report to the SEO and Board of Directors.
• Partner with the Group Legal & Compliance team to harmonize DIFC local regulatory requirements with global group policies and multi-jurisdictional standards.
• Provide expert regulatory and financial crime advice to the Board, SEO, product designers, and operational teams.
• Deliver regular, tailored AML and regulatory compliance training to the local Board, SEO, and operational teams.

Qualifications & Experience

• Regulatory Approval: Currently holding or previously held DFSA Authorized Individual status as CO and MLRO (experience within FinTech firm is highly preferred).
• Experience: Minimum 6–10 years of regulatory compliance and AML experience within the United Arab Emirates/DIFC financial services sector, with at least 3+ years specifically in cross-border payments, B2B FinTech, Electronic Money, or Money Services.
• Technical Knowledge: Deep, hands-on familiarity with the DFSA Rulebook (specifically GEN, COB, and AML modules), Client Money safeguarding rules, DFSA Electronic Prudential Reporting System (EPRS) and the United Arab Emirates goAML reporting system.
• Global Collaboration: Proven experience working within an international headquarters structure, collaborating smoothly with global legal, product, and compliance teams across Asia, Europe, and the Middle East.
• Education & Certifications: Bachelor's degree in Law, Finance, Business, or related fields; CAMS, ICA, or CISI qualifications are strongly preferred.